This privacy policy sets out details about the personal data that we, Spoonful of Sugar Limited (“Spoonful of Sugar”/”We”/”Our”), may collect and process about you.
This Privacy Notice is non-contractual, regularly reviewed and may be amended by us from time to time.
We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website http://www.sosadherence.co.uk/ (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them. For instance, employees and other workers have a separate privacy notice that applies to them.
This website is not intended for children (defined as aged 13 or younger) and we do not knowingly collect data relating to children.
1. Important information and who we are
Spoonful of Sugar Limited, registered as a data controller with the ICO under reference ZA420536, is the controller and responsible for your personal data.
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us at info@sosadherence.co.uk.
Changes to the privacy policy
We keep our privacy policy under regular review and reserve the right to make changes at any time without notice.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier.
- Contact Data includes email address and telephone numbers (optional).
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website. We collect Technical Data via Google Analytics, although these reports are anonymised and aggregated and do not contain personal data.
- Usage Data includes information about how you use our website, products and services.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
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Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you;
- Request information about our services to be sent to you; or
- enquire about possible job opportunities; or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
4. How we use your personal data
Purposes for which we will use your personal data
We process your personal data as it is necessary for our legitimate interests, namely to keep records of user experiences, provide the information you have requested, improve our services, ensure our services remain accurate and up to date, study how our website is used and popular content, and to maintain and grow our business.
We may also need to process your personal data to perform a contract we may enter into with you.
We also process data as required by law, including, to comply with legal obligations such as security obligations in data protection legislation (such as prevention of unauthorised access).
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.
Cookies
When you access our website, cookies will be created. The only cookies you will have on the site are those used to track your Google Analytics.
Cookies are pieces of data created when you visit a site, and contain a unique, anonymous number. Cookies do not contain any personal information about you and cannot be used to identify an individual user. If you choose not to accept the cookie, this will not affect your access to the majority of facilities available on our websites.
Although your browser may be set up to allow the creation of cookies, you can specify that you be prompted before a site puts a cookie on your hard disk, so that you can decide whether to allow or disallow the cookie. Alternatively, you can set your computer not to accept any cookie.
5. Disclosures of your personal data
Your data will be shared internally on a need to know basis to provide you with information requested and, where relevant, to make decisions about the business.
6. International transfers
We do not transfer your personal data outside the European Economic Area (EEA) other than where necessary to destinations deemed by the EU to have adequate data protection safeguards. Exceptionally, we may transfer your personal data to other destinations, in which case we will ensure that other safeguards are put in place, such as standard contractual clauses with any third party overseas data processor.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. Unless there are specific reasons for retaining your personal data for longer (such as if you become a contractor or employee working for us), we will normally permanently delete any such data within five years of first obtaining it via our website.
In some circumstances you can ask us to delete your data: see Your Legal Rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
You have a number of rights in relation to the personal information that we process about you. You:
- Have the right to be informed about your data (as set out in this Privacy Notice);
- Can request access to your personal data;
- Can request that your personal data be rectified if it is inaccurate or incomplete;
- Can request that the processing of your personal data be restricted or erased in certain circumstances, for example, where the data is no longer necessary to meet its purpose;
- Can object to processing in certain circumstances, for example where this is based on legitimate interests or involves direct marketing;
- Can request to receive personal data that you have provided in a structured, commonly used and machine-readable format and to have this transmitted without hindrance where the data is processed on the basis of consent or performance of a contract; and/or
- Can lodge a complaint with the Information Commissioner’s Office (ICO). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.